Privacy Policy

1 Introduction

hbajii ("we", "us", "our") operates the online gambling platform available at hbajii.club (the "Platform"). This Privacy Policy describes how hbajii collects, uses, discloses, and safeguards the personal information of registered players and visitors ("you", "your") when you access or use our Platform, including the hbajii casino, sports betting, and payment services.

This Policy should be read alongside the hbajii Terms and Conditions, which govern the overall use of the Platform. By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

2 Data We Collect

hbajii collects personal information through several channels: directly from you when you register, deposit, withdraw, or contact support; automatically when you browse or interact with the Platform; and from third parties where permitted by law and necessary for identity verification or fraud prevention.

The categories of personal data we may collect include, but are not limited to, the following:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or biometric data unless specifically required by applicable law and with your explicit prior consent.

3 How We Use Your Data

hbajii uses the personal information we collect for the following purposes:

• Account Management: To create, maintain, and administer your hbajii player account, including processing your registration, verifying your identity, and managing account settings and preferences.
• Transaction Processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, Mastercard, and Bank Transfer in BDT and INR, and to maintain accurate transaction records for your account history.
• Identity and Age Verification: To confirm that you are aged 18 or above and to verify the accuracy of the information you have provided, as required by our KYC (Know Your Customer) obligations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover, bonus abuse, and other prohibited conduct as defined in the Terms and Conditions.
• Responsible Gaming: To monitor player behaviour for signs of problem gambling, to enforce deposit limits, self-exclusion requests, and cool-off periods, and to provide responsible gaming resources where appropriate.
• Customer Support: To respond to your enquiries, resolve disputes, process complaints, and deliver live chat and email support services.
• Legal and Regulatory Compliance: To meet our obligations under applicable anti-money laundering (AML) laws, data protection requirements, and any directives issued by competent authorities.
• Platform Improvement: To analyse usage patterns, test new features, improve the hbajii user interface, and optimise the overall betting and casino experience for players in Bangladesh and across South Asia.
• Marketing Communications: Where you have given explicit consent, to send you relevant promotional offers, seasonal bonuses (including Eid, BPL, and Pohela Boishakh promotions), and platform updates via email. You may withdraw this consent at any time by contacting support.

4 Legal Basis for Processing

hbajii processes your personal data on one or more of the following legal bases, depending on the nature and purpose of the processing activity:

• Contractual Necessity: Processing is necessary to perform the contract between you and hbajii — specifically, to provide the gambling and betting services, process transactions, and manage your player account in accordance with the Terms and Conditions.
• Legal Obligation: Processing is required to comply with applicable legal obligations, including KYC/AML requirements, data retention mandates, and responses to lawful requests from law enforcement or regulatory bodies.
• Legitimate Interests: Processing is in hbajii's legitimate business interests — including fraud prevention, IT security, platform improvement, and responsible gaming monitoring — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where no other legal basis applies (for example, for sending optional marketing communications), hbajii will obtain your explicit consent before processing. You retain the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Cookies & Tracking Technologies

The hbajii Platform uses cookies and similar tracking technologies to operate essential Platform functions, analyse user behaviour, and improve the overall experience for players. Cookies are small text files stored on your device when you visit a website.

hbajii uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session management cookies that keep you logged in, security cookies that prevent cross-site request forgery, and cookies that remember your language and currency preferences. These cookies cannot be disabled without significantly impairing Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players interact with the Platform — such as which pages are most visited, average session duration, and which game categories attract the most engagement. This data is used solely to improve Platform performance and does not identify individual users.
• Functional Cookies: Used to remember your preferences, such as your preferred deposit method (e.g., bKash or Nagad), your display settings, and whether you have dismissed certain notifications or banners.
• Third-Party Game Provider Cookies: Certain casino games embedded on the Platform from providers such as Evolution Gaming, Pragmatic Play, Ezugi, Microgaming, NetEnt, and Spribe may set their own cookies. These are governed by the respective providers' privacy policies and are used to operate the game software correctly.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality and performance of the hbajii Platform.

6 Third-Party Data Sharing

hbajii does not sell, rent, or otherwise disclose your personal data to unaffiliated third parties for their own marketing or commercial purposes. We may share your personal data with the following categories of third parties only where necessary and only to the extent required:

• Payment Processors: bKash, Nagad, Rocket, Upay, Visa, Mastercard, and bank transfer partners receive the financial data necessary to process your deposits and withdrawals. These processors operate under their own privacy policies and data security standards.
• Identity Verification Services: Third-party KYC and AML service providers may receive your identity documents (National ID, passport, proof of address) to assist in verifying your account in compliance with applicable regulations.
• Game Technology Providers: Game studios and platform providers (including Evolution Gaming, Pragmatic Play, Spribe, and others) may receive session and gameplay data necessary to deliver their games and calculate outcomes correctly.
• IT and Hosting Providers: Cloud hosting, database management, and cybersecurity service providers who support the technical operation of the Platform may have access to personal data in the course of providing those services. All such providers are bound by strict data processing agreements.
• Law Enforcement and Regulatory Authorities: hbajii may be required to disclose personal data in response to a valid court order, regulatory directive, or law enforcement request. We will comply with such requirements to the extent mandated by applicable law.

7 Payment Data & Financial Privacy

hbajii treats financial data with the highest level of care. We collect only the payment information strictly necessary to process deposits and withdrawals on your behalf. Full card numbers and mobile banking PINs are never stored on hbajii servers — payment authentication is handled directly by the respective payment processor using tokenisation and secure gateway protocols.

All financial transactions on the Platform — whether deposits via bKash, Nagad, or Rocket in BDT, or card transactions in INR — are processed over encrypted connections. hbajii maintains transaction logs for a minimum period as required by applicable AML regulations, after which records are archived or deleted in accordance with our data retention schedule.

As part of our anti-money laundering obligations, hbajii may conduct enhanced due diligence on accounts that exhibit unusual transaction patterns. This may involve requesting additional documentation, temporarily restricting withdrawal access, or reporting activity to relevant authorities where legally required. These measures are in place to protect all players and the integrity of the Platform.

8 Data Retention

hbajii retains personal data for as long as your player account remains active and for a defined period following account closure, as required by applicable legal and regulatory obligations. The following retention guidelines apply:

• Active Account Data: Personal data associated with an active hbajii account is retained for the lifetime of the account plus a minimum of five (5) years following closure, in compliance with standard AML record-keeping requirements.
• Transaction Records: Financial transaction records, including deposits, withdrawals, and bet histories, are retained for a minimum of five (5) years from the date of each transaction.
• KYC Documents: Identity verification documents (National ID, passport copies, proof of address) are retained for a minimum of five (5) years following account closure or the date of document submission, whichever is later.
• Support Communications: Live chat transcripts and email correspondence with the hbajii support team are retained for up to three (3) years from the date of the conversation, unless retention is required for longer by an ongoing dispute or legal proceeding.
• Marketing Consent Records: Records of marketing consent (opt-in and opt-out actions) are retained for the duration of the account and for three (3) years following account closure as evidence of lawful processing.

When the applicable retention period expires, personal data is either securely and permanently deleted from hbajii systems or irreversibly anonymised such that it can no longer be linked to an identifiable individual.

9 Your Rights

Subject to applicable law, you have the following rights in relation to your personal data held by hbajii. To exercise any of these rights, please contact the hbajii support team at [email protected] with the subject line "Data Rights Request". hbajii will acknowledge your request within five (5) business days and will endeavour to fulfil it within thirty (30) business days.

• Right of Access: You have the right to request a copy of the personal data hbajii holds about you, including the categories of data, the purposes for which it is processed, and any third parties with whom it has been shared.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held on your account. Where data has been shared with third parties, hbajii will notify those parties of the correction where reasonably practicable.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to overriding legal retention obligations — for example, AML record-keeping requirements may prevent immediate deletion of transaction data.
• Right to Restrict Processing: You may request that hbajii restrict the processing of your data in certain circumstances — for example, while the accuracy of data is being contested, or where processing is unlawful but you prefer restriction over deletion.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including profiling for responsible gaming purposes. hbajii will cease such processing unless compelling legitimate grounds for continuation can be demonstrated.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

10 Data Security

hbajii employs a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• SSL/TLS encryption for all data transmitted between your device and hbajii servers.
• Encrypted storage of sensitive personal data, including identity documents and financial records, using industry-standard encryption protocols.
• Role-based access controls ensuring that only authorised personnel can access personal data, limited strictly to what is necessary for their job function.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform infrastructure.
• Two-factor authentication options for player accounts to reduce the risk of unauthorised account access.
• Automated monitoring systems that flag unusual login patterns, multiple failed authentication attempts, and suspicious transaction behaviour in real time.

While hbajii takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, hbajii will notify affected players promptly and take immediate remedial action.

You also play an important role in keeping your data secure. Never share your hbajii account password with any third party, use a strong and unique password, and contact [email protected] immediately if you suspect your account has been compromised.

11 Children's Privacy

The hbajii Platform is strictly for adults aged 18 years and over. hbajii does not knowingly collect, store, or process personal data from any person under the age of 18. If a minor accesses the Platform using false information, hbajii bears no liability for such access; however, upon becoming aware of it, we will immediately close the account, void all associated transactions, and delete the personal data of the minor from our systems.

If you are a parent or guardian and believe that a person under 18 in your care has created an account on hbajii, please contact our support team immediately at [email protected]. We will investigate and take prompt action. hbajii encourages responsible use of parental control tools and filtering software to prevent access to gambling websites by minors.

12 International Data Transfers

hbajii operates as an offshore international gambling platform. As a result, your personal data may be transferred to, stored in, or processed in countries outside Bangladesh. This may include countries where the data protection laws differ from those applicable in Bangladesh.

Where personal data is transferred internationally, hbajii takes steps to ensure that an appropriate level of protection is maintained, including by entering into data processing agreements with third-party service providers that contain standard contractual clauses or equivalent safeguards. Transfers to payment processors such as bKash and Nagad are conducted within the Bangladesh jurisdiction and are governed by their respective privacy policies.

By using the hbajii Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Bangladesh for the purposes described in this Policy.

13 Policy Updates

hbajii reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will update the "Last Updated" date at the top of this page. Where the changes are significant, we may also notify registered players by email or via an in-platform notification.

Your continued use of the hbajii Platform following publication of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

Previous versions of this Privacy Policy may be requested from the hbajii support team and will be provided within a reasonable timeframe upon written request.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way hbajii handles your personal data, please do not hesitate to get in touch with our support team. We are committed to addressing all privacy-related queries promptly and transparently.

• Live Chat: Available directly within the hbajii Platform during your logged-in session — typically the fastest way to reach us.
• Email: [email protected] (plain text — not a clickable link). Use the subject line "Privacy Enquiry" for data-related requests.
• Response Time: Email responses within 24 hours during Bangladesh Standard Time (BST, UTC+6) business days.
• Data Rights Requests: Use the subject line "Data Rights Request" and include your registered email address and account username to allow us to verify your identity and process your request efficiently.

For responsible gaming support, self-exclusion requests, or deposit limit adjustments, please visit the Responsible Gaming page or contact our support team with the subject line "Responsible Gaming Request".